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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 14 of 29 her story. From this dubious premise, Defendant then argues that Ms. Ransome should therefore be punished by having to make burdensome and invasive disclosures of such things as her boyfriend's cell phone number and information from her current bank account. Unwilling to confine her attacks to Ms. Ransome, Defendant then levels attacks on the professionalism of Ms. Giuffre’s legal counsel, stating in her brief: “One can hardly imagine a better motive to fabricate testimony that the type of lottery win. To make it even better, there is no purchase price for the ticket, because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication” is directly refuted by the multiple pictures and e-mails non-party Ms. Ransome produced — documentary evidence that Defendant fails to discuss in her brief. Moreover, non-party Ms. Ransome is identified as a passenger on Epstein’s own flight logs: "le waa | Santee 1 A nA _L nate. _ See es a gate | [Men] tp |] eereenesnas = i] i ee = {0 iS “SAG N4O4 SE 2 |ewe [TEST | hag! Sipe Abs LnRAneoe mt ( ra 4 a) oe ay 2 , Ewe | _ Mash EB uit De | ve : ai 2 1 ~ fev PRI gay GERALD Lercae ty Wii Vl Ve re Rr | ee “pact | GeRALo Lépcaugy Ey We [pana Nose Trsa_ lawn | ie aie ee bite Vcertity thel thea etalamonle rads by mann this orm ane Lue, Non-party Ms. Ransome’s fulsome production included items such as multiple e-mails with Sarah Kellen, a known key conspirator and recruiter of females, and Leslie Groff, Defendant’s other co-conspirator who was also named in the non-prosecution agreement. These e-mails are direct evidence of the trafficking of females for the purpose of sex, and the use of fraud and manipulation to accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the years that she swore under oath that she was hardly around. Ms. Ransome’s testimony proves that what little Defendant did say during her deposition was far from the truth. 10